November 17, 2022
| The Honorable Jessica Rosenworcel Chairwoman Federal Communications Commission 45 L Street, NE Washington, D.C. 20230 |
The Honorable Alan Davidson Assistant Secretary and Administrator National Telecommunications and Information Administration 1401 Constitution Avenue, NW Washington, D.C. 20230 |
Dear Chairwoman Rosenworcel and Administrator Davidson,
Wireless spectrum is essential to America’s future technology leadership, industrial might, and global competitiveness. That’s why a remarkably broad swath of companies and organizations – representing manufacturing, automotive, agriculture, energy, retail, commercial real estate, communications, media, and supply chain industries, as well as schools, libraries, and civil society groups – support an inclusive approach to spectrumpolicy. America needs a balanced policy that considers the needs of an extraordinarily diverse range of spectrum stakeholders who are investing in advanced networks to power the “5G economy”.
As we consider new spectrum options that can be made available to serve the American people, we urge you to build on the demonstrated success of the Citizens Broadband Radio Service (CBRS) spectrum sharing model.The innovative CBRS licensing framework has driven innovation in the next generation of wireless networks. These networks advance investment, protect critical U.S. leadership and security by enabling ongoing Department of Defense (DoD) and Federal missions in shared bands, drive innovation and competition, and maximize efficient use of the limited yet essential spectrum resource. Every day, more devices, services, and organizations require access to a wider array of spectrum resources. Implementing approaches that promote a wide variety of advanced communications applications will powerfully advance the public good.
Spectrum Sharing Advances Investment
The Federal Communications Commission (FCC) first authorized commercial equipment in the CBRS band just three years ago and completed its auction of shared licenses just two years ago. In that short timeframe, CBRSis now being used throughout the country with over 285,000 CBRS base station devices (CBSDs) already deployed in under three years. For comparison, the commercial wireless industry has built 418,887 cell sites overits entire 40-year history. (During the same three-year period that CBRS has been active, cellular providers built 69,543 cell sites – of which more than 10,000 use CBRS.) As further evidence of a dynamic equipment ecosystem, the FCC has certified 187 different CBRS base station models and 496 different end user client devices, ranging from traditional smartphones and IoT modules and gateways to security cameras, barcode scanners, and building management sensors. Use of the CBRS band is vibrant and growing at an impressive pace.
Spectrum Sharing Drives Innovation
The CBRS framework provides users with flexibility to choose from the broadest range of technologies and service models, driving innovation and competition in the private wireless market. Because CBRS spectrum is accessible to a wide variety of operators, it provides options for operators in suburban, rural and remote areas that are not adequately served by traditional carriers, while also enabling private network users to customize networks to meet their needs.
CBRS is emerging as the home spectrum band for a myriad of advanced wireless use cases. For example:
- CBRS-powered networks are improving the efficiency of supply chains, warehouses, and critical
- CBRS is enabling advanced manufacturing techniques that enhance worker productivity and safety, helping American firms maintain their competitive edge.
- Farms are using CBRS to increase efficiency, yields, and cost
- Transportation and shipping hubs are using private networks to support automated-guided vehicles moving cargo and to improve real-time logistics through faster wireless communications.
- Schools and libraries are using CBRS to close the digital divide and homework gap for underserved
- Hospitals are using CBRS to triage and monitor patients, including by connecting outdoor hotspots to indoor networks, so nurses can test and triage patients outside the hospital setting.
- Airports, entertainment venues, and stadiums are using private CBRS networks to improve the guest experience by providing additional and dedicated bandwidth for venue operations.
These and many other use cases demonstrate that CBRS networks – along with complementary technologies like industrial automation, artificial intelligence, precision agriculture, and edge computing providers – are essential to enabling an enterprise technology stack that propels American innovation and advanced industrial practices.
Spectrum Sharing Spurs Competition
CBRS enables “converged” delivery models that both compete with and bolster traditional wireless network services provided over exclusively licensed spectrum. It is also proving complementary to Wi-Fi. No single private entity or industry should hold the key to an enterprise, university, or other entity’s ability to access the public airwaves needed to deploy an innovative, purpose-built network. The CBRS framework helps ensure that does not happen. This competition drives still more innovation, creating a virtuous cycle.
Spectrum Sharing Maximizes Efficiency of a Limited Resource
CBRS uniquely combines auctioned and non-auctioned authorizations into a single frequency band, maximizing the scale of the equipment ecosystem to the benefit of many different types of users. The FCC conceived of the CBRS shared-license model to allow the DoD to avoid band clearing (and its associated costs) and continue its critical operations while also allowing a wide variety of commercial operators to use spectrum in the same band. This tiered spectrum sharing model ensures the protection of America’s national security interests while allowing other users to make the most of a critical resource.
Both the auctioned (Priority Access License, or PAL) and non-auctioned or licensed-by-rule (General Authorized Access, or GAA) portions of the CBRS bands have demonstrated substantial success. The PAL auction resultedin 228 diverse winning bidders – almost 10 times the number of winning bidders in the exclusive-use 3.45 GHz band. PAL winners included wireless internet service providers and electric utilities, cable operators, and
nationwide and regional mobile network operators. The GAA portion of the band hosts nearly 900 different users, including factories, cities, school districts, hospitals, research centers, schools, public libraries, utilities, and other critical infrastructure. Most importantly, unused PAL spectrum does not lie fallow, and can be efficiently put to use by GAA spectrum users.
That all of these different user types can “cohabitate” in a single spectrum band is an achievement to be celebrated and replicated. At the same time, as new technologies and techniques become available to make the CBRS automated dynamic sharing regime even more efficient, it provides a framework for iterative improvement over time.
Spectrum Sharing Is Internationally Recognized
CBRS has become a model for spectrum sharing around the world. Recognizing the value of midband private5G networks, other countries are also working to make spectrum available in new ways for new users and uses.For example, Germany, France, the United Kingdom, Japan, Brazil, Sweden, and other countries have alldesignated substantial amounts of shared midband spectrum for private and local networks.
- In Germany, the Frankfurt Airport is working toward deploying a private 5G network to “control data and voice communication autonomously.”
- In Japan, Sony is working to deploy internet service that will minimize “service disruptions caused by heavy traffic” in certain residential complexes.
- In the K., Verizon is using shared midband spectrum to develop a private 5G wireless network for the Associated British Ports.
- In Europe, CEPT is studying CBRS-like dynamic sharing of low/medium power networks with satellite systems in the 3.8-4.2 GHz band.
With CBRS, the United States has shown the world that spectrum can be made available without requiring inefficient allocations for a wide variety of different uses. In light of other countries’ moves toward greater spectrum sharing, the United States should extend its leadership by nurturing and growing CBRS.
Conclusion
The undersigned parties believe that the CBRS allocation has fulfilled its promise as the “innovation band” in an incredibly short period of time. The framework should be advanced for future spectrum allocations, including in thelower 3 GHz band, to enable greater competition, innovation, efficiency and American leadership. Thank you for continuing to support a spectrum policy that demonstrates America’s inventive spirit at its finest.
Sincerely,
Airspan Networks
Amazon.com Services LLC
American Library Association
CalChip Connect
Celona Inc.
Charter Communications,Inc.
Comcast Corporation
Cox Communications, Inc.
Deere & Company
Dynamic SpectrumAlliance
Federated Wireless
Hewlett Packard Enterprise Company(HPE)
HRMavenir Systems, Inc.
JBG SMITH Properties
Midcontinent Communications
Motorola Solutions, Inc.
NCTA – The Internet & TelevisionAssociation
Open Technology Institute at NewAmerica
Pollen Mobile LLC
Public Knowledge
Purdue Research Foundation
Shure Incorporated
The Schools, Health & LibrariesBroadband Coalition (SHLB)
US Ignite
Weavix
WISPA – Broadband Without Boundaries
CC: The Honorable Brendan Carr, Commissioner, Federal Communications Commission The Honorable Geoffrey Starks, Commissioner, Federal Communications Commission
The Honorable Nathan Simington, Commissioner, Federal Communications Commission
